Stockstrom v. Commissioner
United States Tax Court
The grantor created trusts for the benefit of her children and grandchildren, expressly reserving the right to amend the trust agreements as to all provisions except those relating to the distribution of trust funds. The income and, under some conditions, the principal of the trusts were distributable among the several beneficiaries of each trust at the discretion of the trustees, who were grantor's husband and another individual.
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The grantor created trusts for the benefit of her children and grandchildren, expressly reserving the right to amend the trust agreements as to all provisions except those relating to the distribution of trust funds. The income and, under some conditions, the principal of the trusts were distributable among the several beneficiaries of each trust at the discretion of the trustees, who were grantor's husband and another individual. Under her reserved powers, and by amendment of the trust agreements, the grantor could remove the trustees at will. Held, that the grantor retained sufficient…
1Opinion of the Court
OPINION.
Smith, Judge:
This proceeding involves liabilities asserted against the petitioners as transferees for deficiencies in income tax of Bertha Stockstrom, now deceased, for the calendar years 1939,1940, and 1941 in the respective amounts of $4,558.61, $5,624.64, and $10,545.03.
The question in issue is whether the income of three trusts created by decedent for the benefit of her children and grandchildren was taxable to her as settlor of the trusts.
It is stipulated that if decedent was taxable on the income of the trusts then petitioners herein are liable as transferees for the…
2Cases cited2 opinions
- Helvering v. CliffordSupreme Court of the United States · 1940
- Stockstrom v. CommissionerUnited States Tax Court · 1944
3Cited by10 opinions
- Corning v. CommissionerUnited States Tax Court · 1955
- Shapero v. CommissionerUnited States Tax Court · 1947
- Estate of Wall v. CommissionerUnited States Tax Court · 1993
- Braun v. CommissionerUnited States Tax Court · 1984
- Corning v. CommissionerUnited States Tax Court · 1955
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